https://www.taxtmi.com/caselaws?id=284501 Article 11(1) of the India-Cyprus DTAA taxes interest only when it is actually paid or received, so notional or contingent interest on FCCDs that neither accrued nor was paid during the year could not be taxed. The transfer pricing adjustment under Chapter X was therefore unsustainable because section 92 cannot be used to bring hypothetical income to tax where the charging provisions are not satisfied. The note further states that only interest actually received is within the treaty's taxing scope, not an expected return dependent on future contingent events. en-us Fri, 09 Aug 2019 00:00:00 +0530 Fri, 22 Nov 2019 10:00:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284501 Article 11(1) of the India-Cyprus DTAA taxes interest only when it is actually paid or received, so notional or contingent interest on FCCDs that neither accrued nor was paid during the year could not be taxed. The transfer pricing adjustment under Chapter X was therefore unsustainable because section 92 cannot be used to bring hypothetical income to tax where the charging provisions are not satisfied. The note further states that only interest actually received is within the treaty's taxing scope, not an expected return dependent on future contingent events. Case-Laws Income Tax Fri, 09 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284501